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 Previous: The Amateur Radio Crossword Puzzler |  Next: A Message from ARRL President Jim Haynie, W5JBP |
By David Sumner, K1ZZ
ARRL Chief Executive Officer
September 1, 2005
Editor's note: Typically, only ARRL members get to read the "It Seems to Us ..." editorials that run each month in QST. We're posting this editorial that appears in the September issue of QST in the hope that both ARRL members and nonmembers might appreciate it and find it informative.
The day before this issue of QST went to the printer, the FCC released a Notice of Proposed Rule Making (NPRM) on Amateur Radio operator licensing requirements. The NPRM in WT Docket No. 05-235 addresses proposals contained in 18 petitions for rulemaking, on which more than 6,200 comments were filed. One of the 18 petitions, RM-10867, was filed by the ARRL in early 2004. RM-10867 reflected the ARRL Board's view that Amateur Radio needs a new entry-level license. Similar views were expressed in some of the other petitions. Because the ARRL petition picked up the restructuring of amateur licensing where the FCC had left off in a partially completed proceeding, WT Docket 98-143, we styled it "Restructuring II."
The ARRL proposal envisions three classes of amateur license. The top level would continue to be the Amateur Extra license, with the same requirements (including Morse code) and privileges as at present. The intermediate level would be the General license, but without a Morse requirement. The entry level would be new, more similar to the old Novice (no longer available but fondly remembered) than to the present Technician license, but with limited HF and VHF privileges more appropriate to the current state of the art. This structure, very similar to what is proving successful in the United Kingdom and some other countries, strikes most thoughtful observers as quite sensible although there are differences as to detail--especially with regard to how to incorporate existing Technician licensees into the new structure.
What the FCC is proposing falls far short of restructuring. In the face of what still seem to us to be sound arguments, the FCC is not proposing any changes at the point of entry into Amateur Radio. Indeed, the FCC is proposing to close off one of the available routes to HF privileges. Unless the Commission can be persuaded to adjust its course, the FCC and the amateur community will miss a great opportunity to better position Amateur Radio as a 21st Century avocation.
After reviewing the 18 petitions, some of them more than two years old, all the FCC has proposed is to drop the Morse code examination element, Element 1, from the list of available examinations and from the list of requirements for any class of amateur operator license. The proposal follows the decision of the ITU 2003 World Radiocommunication Conference to delete the requirement that amateur licensees demonstrate Morse ability before being allowed to operate below 30 MHz, and instead to leave it to each administration to determine whether or not to impose such a requirement. In this proceeding the FCC has tentatively concluded that maintaining a Morse requirement would not be in the public interest, but that no other changes to licensing requirements or privileges are desirable.
The Commission's apparent determination to do as little as possible leads to a strange result. Presently there are two categories of Technician licensee: those who have passed a Morse exam and those who haven't. Morse credit entitles a Technician licensee to the limited Novice HF privileges, including SSB and data in part of the 10-meter band, in addition to the full privileges above 30 MHz that are granted to all Technicians. In dropping Element 1, the FCC has not proposed to extend the limited Novice HF privileges to all present and future Technicians. This is in contrast to what the Commission did in 2000, when it reduced the Morse requirement for a General license from 13 to five words per minute. Because any Technician licensed before 1987 had passed the same written exam as for General, the only difference between the two licenses at the time being code speed, the FCC allowed these Technicians to apply for an administrative upgrade to General. Now, having been relieved of the obligation to require Morse ability before granting a licensee access to frequencies below 30 MHz, the FCC proposes simply to eliminate the path to HF access previously afforded by the Morse exam. Thus, the elimination of the requirement will lead not to a gain for Technicians, but to a loss.
The ARRL had proposed retaining the Morse requirement for the Amateur Extra license on the grounds that the most accomplished radio amateurs should possess at least basic Morse capability in their portfolio of operating skills. The FCC did not find this argument, or those of other Morse advocates, to be persuasive. This is by no means the end of the discussion, either on this or any other aspect of the NPRM. Comments may be made directly to the FCC until 60 days after publication of the NPRM in the Federal Register (which at this writing has not taken place). Replies to comments filed by others may be offered for an additional 15 days. Your elected representatives on the ARRL Board are also open to comments and suggestions as we study the NPRM and formulate a response on behalf of the ARRL membership.
As always, in formulating comments on an FCC proposal the best place to start is with the proposal itself. The 30-page document is available on the Web. If your concern is the Morse requirement, pay particular attention to paragraphs 16-20. Instructions on how to file comments and how to view the comments filed by others are in paragraphs 54-58.
The NPRM is not the final word. Let's not miss the opportunity to push the proceeding in a more positive direction.--David Sumner, K1ZZ
